Justia Civil Rights Opinion Summaries

Defendant Frank Johnson was convicted for operating after habitual offender revocation. Johnson appealed, arguing that the superior court erred in denying his motion to strike an earlier conviction offered by the State to enhance his current charge to a Class C crime because the prior conviction resulted from a guilty plea that was allegedly constitutionally flawed. At issue was whether Johnson had the right to collaterally attack the prior conviction. The Supreme Court affirmed after examining relevant federal and state precedent, holding (1) a criminal defendant may not collaterally attack a prior conviction during proceedings related to a different offense unless the defendant alleges a violation of the Sixth Amendment right to counsel; and (2) because Johnson did not assert a violation of his Sixth Amendment right to counsel as the basis for his collateral attack on his prior conviction, his motion to strike was properly denied without further hearing.

Defendant William Hanaman was convicted of intentional or knowing murder following a jury trial. Hanaman appealed, contending that the trial court erred in refusing to instruct the jury on the affirmative defense of adequate provocation to reduce the murder charge to manslaughter pursuant to Me. Rev. Stat. 17-A, 201(3). The trial court determined that an adequate provocation instruction was subsumed by instructions that were given on self-defense and imperfect self-defense. The Supreme Court affirmed, holding that the evidence was not legally sufficient to support a jury instruction on the affirmative defense of adequate provocation, and therefore, the court did not err in refusing to give an adequate provocation instruction in this case.

Following a bench trial in the district court, Defendant John Maynard was convicted of operating while his license was suspended, with a prior conviction (OAS). Maynard appealed, arguing that the Secretary of State's certification of the notice of Maynard's suspension failed to prove the notice element of the OAS charge. The Supreme Court vacated the judgment of the district court, holding that the Secretary of State's certification on its face was inadequate to prove that the court provided Maynard notice of his license suspension, as a Secretary of State's certification that does not set forth any underlying facts pertaining to the notice of suspension does not suffice as proof of notice.

Timothy Robbins entered a conditional plea of guilty to and was convicted of operating under the influence (OUI), with two prior convictions, and operating after suspension. Robbins appealed, contending that the trial court erred in denying his motion to strike two prior uncounseled misdemeanor OUI convictions, which reflected that he appeared pro se but were silent as to the procedures taken to ensure that his constitutional right to counsel was satisfied. The Supreme Court affirmed the judgment of conviction, holding that Robbins could not prevail on the record because, as no evidence was presented to the contrary, the Court presumed the regularity that attaches to the final judgment of a conviction.

Following a nonjury trial, James Soucy was convicted of operating a motor vehicle under the influence of intoxicants (OUI) with one previous OUI conviction within a ten-year period. Soucy appealed, arguing that the evidence of impairment from his use of prescription drugs was insufficient to convict him of OUI. The Supreme Court affirmed, holding that because there was sufficient evidence in the record for the district court to find, beyond a reasonable doubt, that, while operating his motor vehicle, Soucy was impaired, to some extent, by his consumption of prescription drugs, the district court did not err in its judgment.

Chad Gurney was convicted of murder and arson following a jury-waived trial. The Supreme Court affirmed the judgment of the trial court, holding that the court did not err in (1) denying Gurney's motions to suppress evidence found on his Facebook account, laptop computer, and cell phone; (2) admitting evidence of a reference to a beheading video found in unallocated space on the hard drive of Gurney's laptop computer; (3) not addressing in its findings the journals and emails that Gurney offered as evidence of his preexisting and ongoing psychosis; and (4) finding that Gurney did not carry his burden of proving that he suffered from a mental disease or defect that substantially affected his ability to appreciate the wrongfulness of his conduct.

Mallory McPartland appealed from a judgment of conviction entered in the criminal docket upon her conditional guilty plea to operating under the influence (OUI) following the denial of her motion to suppress evidence. McPartland argued that the suppression court erred in concluding that the police officer she encountered at an OUI roadblock had a reasonable articulable suspicion of impairment that was sufficient to justify additional sobriety screening. The Supreme Court affirmed the suppression court's finding that the officer had reasonable suspicion to refer McPartland to secondary screening in this case, holding that the court correctly concluded that satisfaction of the reasonable articulable suspicion standard justifies directing a motorist to secondary screening following an initial roadblock stop.

After a jury trial, Kenny Ouellette was convicted of reckless conduct. Ouellette appealed, arguing that the superior court erred in (1) declining to instruct the jury on his justification of self-defense to the charge of reckless conduct, and (2) failing to inform the jury of the parties' out-of-course resolution that resulted in a dismissal of a count of criminal mischief stemming from the same incident. The Supreme Court vacated the judgment of conviction, holding (1) the trial court's instruction to the jury that it could not consider self-defense as to the charge of reckless conduct was erroneous, and (2) the error was not harmless. Remanded for a new trial.

Following a jury trial, Jesse Guyette was convicted of unlawful possession of scheduled drugs. Guyette appealed, arguing that the superior court erred by admitting several statements at trial pursuant to the Me. R. Evid. 804(b)(3) exception to the hearsay rule for statements against penal interest. The Supreme Court vacated Guyette's conviction, holding (1) the trial court abused its discretion by admitting the out-of-court statements of a person who was not a codefendant at trial but whose statements implicated Guyette because the statements did not fall within the Rule 804(b)(3) hearsay exception; and (2) the court's error in admitting those statements was not harmless.

Raymond Cloutier appealed from a judgment entered in the district court granting Robin Turner's motion to enforce the child support provisions of a 1992 amended divorce judgment. The Supreme Court affirmed the judgment, holding (1) Turner had standing to bring the motion even though the children were above the ages of eighteen because, although the obligation to provide future support ends when the child reaches majority, liability for arrearages does not terminate then; (2) where child-support arrearages are considered money judgments and there is no statute of limitations for money judgments, Turner's claim of overdue child support was not time-barred; (3) the court's failure to apply the statute of limitations did not deprive Cloutier of his constitutional right of equal protection because Cloutier was not treated any differently than fathers who are subject to child support enforcement stemming from a paternity action; and (4) Cloutier failed to make the showing necessary to establish the defense of laches.